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By: Tiffany D. Bell, Esq. In 2010, Congress added to the anxiety of tax practitioners when it expanded the statute of limitations for the IRS to assess income taxes to six years when a taxpayer fails to include Form 8938 with his tax return. Taxpayers use Form 8938 to report to IRS foreign bank accounts and other specified foreign financial
By: Randall P. Andreozzi, Esq. The IRS announced on Wednesday that it will officially end the 2014 Offshore Voluntary Disclosure Program (affectionately known to practitioners as the “OVDP”) on September 28, 2018. The Agency urged taxpayers who still have not come forward to do so before the program ends. The 2014 OVDP is the last evolution of the program IRS
By: Gary P. Bluestein, Esq. The general view of most accountants and attorneys we talk to is that tax debt is not dischargeable in Bankruptcy. When we tell them that a tax debt may indeed be dischargeable, people are typically very surprised. While there are many factors that determine whether a tax debt is dischargeable in a bankruptcy filing (primarily
In a court-reviewed opinion published on January 29, 2018, the U.S. Tax Court in Coffey, et. al. v. Commissioner, 150 T.C. No. 4, found in favor of the taxpayers and dismissed the Internal Revenue Service’s Statutory Notices of Deficiency against them as time barred. Andreozzi Bluestein LLP represented the Petitioners in this case before the Tax Court. The Petitioners claimed
By: Heather L. Marello, Esq. The Bank Secrecy Act of 1970, Pub. L. 91-507, 84 Stat 114 (Oct. 26, 1970), addressed the government’s desire to monitor the use of foreign bank accounts for illegal activities by authorizing the Secretary of the Treasury to require U.S. citizens, residents, and others to “keep records, file reports, or keep records and file reports,
By: Michael J. Tedesco, Esq. On December 22nd, 2017 with one stroke of a pen, president Trump signed into law the most sweeping tax law changes in a generation. For the first time in over 30 years tax professionals will confront significant changes in the tax law that will impact planning, reporting and enforcement matters. While the true impact of